GHS Labeling — Dangerous Goods Transport Classification and SDS Cross-Checking
Interlink編集部What Is GHS Labeling?
GHS labeling is a system that displays the hazardous and harmful properties of chemicals on containers and packaging using pictograms, signal words, hazard and precautionary statements.
GHS stands for Globally Harmonized System of Classification and Labelling of Chemicals. It is an international system for classifying and labeling chemicals.
In freight forwarder operations, GHS labeling serves as an initial checkpoint to determine whether cargo contains hazardous chemicals. However, the presence of GHS labeling does not necessarily mean the cargo qualifies as dangerous goods under international transport regulations.
When GHS labeling is present, it is important to also check the SDS, UN number, hazard class, packaging group, dangerous goods declaration, and acceptance conditions of the shipping line, airline, CFS, and warehouse involved.
Scope Covered in This Article
| Item | Content Covered in This Article | Content Covered in Other Articles |
|---|---|---|
| Basics of GHS Labeling | Explains the labeling system that communicates the hazardous properties of chemicals through labels and SDS. | Detailed regulatory explanations of the GHS system itself are covered in the Chemical Management System article. |
| Interpretation in Freight Forwarder Operations | Covers how to connect GHS labels and SDS to the confirmation of dangerous goods during transport. | GHS classification work and label creation by manufacturers and importers are covered in articles aimed at chemical producers. |
| Differences Between GHS Labels and Dangerous Goods Transport Labels | Clarifies the differences between chemical hazard communication and marine/air transport dangerous goods markings. | Requirements for affixing dangerous goods labels and packaging are covered in the Dangerous Goods Labels and Dangerous Goods Declaration articles. |
| The 9 GHS Pictograms | Organizes pictograms and key check points in the order that freight forwarders can most easily connect them to transport classification. | Detailed classification criteria for each GHS class are covered in the GHS Classification and SDS articles. |
| Cross-checking with SDS | Covers practical cross-checking of GHS labels, transportation sections of SDS, UN numbers, and dangerous goods classes. | How to create SDS and detailed explanations of each section are covered in the SDS article. |
| Contradictions with Non-Dangerous Goods Declarations | Covers verification when shipper declarations, non-dangerous goods certificates, physical labels, and SDS differ. | Formats and issuance practices of non-dangerous goods certificates are covered in the Non-Dangerous Goods Certificate article. |
| Precautions by Transport Mode | Covers cases where judgments differ for marine transport, air transport, CFS in-gate, and warehouse in-gate. | Details of the IMDG Code, IATA Dangerous Goods Regulations, and CFS Dangerous Goods Handling are covered in their respective articles. |
| Handling Operational Issues | Covers responses when GHS labeling is overlooked, transport information conflicts arise, or in-gate/loading is halted. | Cost bearing after accidents, damage claims, and contractual liability decisions are covered in the Cargo Incidents and Cost Bearing article. |
Overview of GHS
GHS is an international system designed to clearly communicate the hazards and risks of chemical substances.
It classifies hazards such as explosiveness, flammability, oxidizing properties, high-pressure gases, corrosiveness, acute toxicity, health hazards, and environmental hazards, and conveys this information to relevant parties through labels and Safety Data Sheets (SDS).
GHS labeling provides essential information for businesses involved in the manufacture, import, sale, storage, handling, or transportation of chemicals to understand their hazards.
However, GHS is a system for communicating chemical hazards and does not directly define dangerous goods classification for maritime or air transport. Determining whether a substance is a dangerous good for transport requires consulting the transport information section of the SDS, the UN number, hazard class, packing group, as well as the IMDG Code and IATA Dangerous Goods Regulations.
Relationship with Domestic Laws and Transport Regulations
In Japan, several laws relate to SDS and label displays compliant with GHS. Additionally, in actual international transport, dangerous goods regulations for maritime and air transport must also be verified.
| Category | Main Role | Freight Forwarder Practical Perspective | Notes |
|---|---|---|---|
| Chemicals Substances Control Law | Concerns provision of SDS and label-based information transfer between business operators for specified chemical substances. | This serves as the entry point for confirming hazard and composition information as chemical products. | Should be treated separately from hazardous goods classification for transport. |
| Industrial Safety and Health Law | Involves management of label displays, SDS, and risk assessments for chemicals handled in workplaces. | Leads to safety verification in cargo handling, warehouses, CFS, and work sites. | Avoid confusing workplace safety labels with transport dangerous goods labels. |
| Poisonous and Deleterious Substances Control Law | Regulates labeling, handling, storage, and transfer of poisonous and deleterious substances. | For chemicals classified as poisonous/deleterious substances, pay attention not only to transport arrangements but also to storage and handling conditions. | Classification as poisonous/deleterious substances may not align with international transport dangerous goods classes. |
| IMDG Code | Relates to classification, packaging, marking, declaration, segregation, and stowage of dangerous goods in maritime transport. | Serves as the standard for shipment, CFS in-gate, consolidation permissibility, and shipping line acceptance decisions. | Check not only GHS labels but also transport-related SDS sections and UN numbers. |
| IATA Dangerous Goods Regulations | Governs classification, packaging, labeling, declaration, and carriage eligibility of dangerous goods for air transport. | Confirm if air transport is permitted and whether handling differs between passenger and cargo aircraft. | Cargo accepted by sea may be rejected for air carriage. |
| Warehouse and CFS Acceptance Criteria | Involves acceptance decisions based on storage facilities, cargo handling systems, consolidation conditions, and site safety. | Warehouses and CFS may request additional documentation for cargo displaying GHS labels. | Even if cargo is not legally classified as dangerous goods for transport, operational site checks may be required. |
Domestic laws related to GHS labeling primarily provide a framework for communicating hazard information about chemicals. In contrast, international transport requires confirming UN numbers, dangerous goods classes, packaging, labels, and declarations based on transport-related hazards.
Main Label Elements of GHS Labels
GHS labels include several elements to communicate the hazardous and harmful properties of chemical products.
| Label Element | Meaning | Verification in Freight Forwarder Operations | Actions If Inconsistencies Are Found |
|---|---|---|---|
| Chemical Name | The product name, chemical name, or mixture name. | Check that the names on the invoice, SDS, dangerous goods declaration, and physical label match. | Request the shipper or manufacturer to identify the relevant product. |
| Pictograms | Red diamond-shaped marks indicating hazardous properties. | Use the transportation information section of the SDS as the initial confirmation for dangerous goods transport. | Avoid determining transportation hazard solely based on pictograms. |
| Signal Words | Words indicating the degree of hazard or harmfulness. | Cross-check with the SDS due to the potential for high hazard. | Confirm whether the SDS is outdated or refers to a different product. |
| Hazard Statements | Statements explaining the types of hazard and impacts on health or the environment. | Verify whether the product qualifies as dangerous goods for transport purposes. | If contradicting the SDS transportation information, request confirmation from the manufacturer. |
| Precautionary Statements | Precautions for handling, storage, first aid, disposal, etc. | Check precautions relevant for warehouses, CFS, cargo handling, and storage. | Confirm acceptance conditions with the warehouse or CFS. |
| Supplier Information | Information on the manufacturer, importer, or supplier. | Confirm as a contact point for obtaining the SDS or additional documentation. | If unclear, request official supplier documents from the shipper. |
Differences Between GHS Labels and Dangerous Goods Transport Labels
While GHS labels and dangerous goods transport labels may look similar, their purposes and the points to verify are different.
| Comparison Item | GHS Label | Dangerous Goods Transport Label | Practical Notes for Freight Forwarders |
|---|---|---|---|
| Purpose | Communicate chemical hazards and harmful properties to handlers. | Communicate transport hazards to carriers, warehouses, CFS, airlines, and shipping lines. | The purposes differ, so transport eligibility should not be judged by GHS labels alone. |
| Main Standards | GHS, domestic laws, SDS, and labeling systems. | IMDG Code, IATA Dangerous Goods Regulations, and conditions of acceptance by each carrier. | Check according to each mode of transport. |
| Displayed Locations | Product containers, packaging, SDS, chemical labels. | Transport outer packaging, dangerous goods packaging, dangerous goods declarations, transport documents. | Separate confirmation for product container labels and transport outer packaging labels is necessary. |
| Main Information | Pictograms, signal words, hazard and precautionary statements. | UN number, proper shipping name, hazard class, packing group, dangerous goods labels. | Confirm presence of UN number and hazard class. |
| Documents to Verify | SDS, product labels, manufacturer documents, non-dangerous goods certificates. | Transportation section of the SDS, dangerous goods declarations, carrier acceptance conditions. | Always check the transportation section of the SDS. |
| Practical Considerations | Do not assume cargo is legally dangerous goods in transport based solely on GHS labeling. | If transport labels or UN numbers are required, cargo typically cannot proceed as general cargo. | Use GHS labels as an initial check and proceed to verify under transport regulations. |
For freight forwarders, an important point is to use GHS labels as the initial step to identify potential dangerous goods, then verify the SDS, UN number, hazard class, and acceptance conditions for each transport mode.
The 9 GHS Pictograms and Their Connection to Transport Classification
GHS labeling uses pictograms enclosed in a red diamond frame. The common pictograms include Explosives, Flame, Flame Over Circle, Gas Cylinder, Corrosive, Skull and Crossbones, Exclamation Mark, Health Hazard, and Environmental Hazard.
However, not all GHS pictograms directly correspond with transport-related dangerous goods classification at the same level of severity. In freight forwarder operations, it is important to distinguish which pictograms are more likely to require transport-related verification.
The table below is arranged not by the standard GHS order, but by the order in which freight forwarders typically focus when checking for transport dangerous goods classification.
| GHS Pictogram | Main Meaning | Relation to Transport Dangerous Goods Classification | Checks in Freight Forwarder Practice |
|---|---|---|---|
| Explosives | Includes explosives, self-reactive substances, organic peroxides, etc. | This pictogram is strongly linked to transport dangerous goods classifications. | Always verify SDS transport information section, UN number, class, and acceptance status by shipping line or airline. |
| Flame | Indicates flammable, combustible, self-heating substances, etc. | This pictogram is strongly linked to transport dangerous goods classifications. | Check flashpoint, UN number, hazard class, packaging group, and sea/air transport conditions. |
| Flame Over Circle | Oxidizing substances, oxidizing liquids, oxidizing solids, etc. | This pictogram has a strong association with transport dangerous goods. | Confirm compatibility with mixed loading, segregation requirements, and acceptance conditions of shipping line and CFS. |
| Gas Cylinder | High-pressure gases, compressed gases, liquefied gases, etc. | This pictogram is strongly related to transport dangerous goods. | Check gas type, container, UN number, air transport acceptance, and CFS acceptance. |
| Corrosive | Indicates skin corrosion, serious eye damage, metal corrosion, etc. | May correspond to transport dangerous goods classification. | Confirm metal corrosiveness, container type, leakage impact, and classification under Class 8. |
| Skull and Crossbones | Highly acute toxic substances. | This pictogram often corresponds to transport dangerous goods classification. | Check toxicity category, UN number, packing conditions, and acceptance restrictions. |
| Environmental Hazard | Includes aquatic toxicity and other environmental hazards. | Leads to confirmation of marine pollutants and environmental hazard status. | Confirm Marine Pollutant status and labeling/declaration requirements for sea transport. |
| Exclamation Mark | Indicates irritants, skin sensitizers, mild acute toxicity, etc. | May not always classify as dangerous goods for transport. | Do not classify as dangerous goods solely based on this pictogram; check SDS transport information section. |
| Health Hazard | Includes carcinogenicity, reproductive toxicity, organ toxicity, respiratory sensitization, etc. | May not match transport dangerous goods classification directly. | Distinguish handling and storage precautions from transport dangerous goods classification. |
The pictograms that should be prioritized for transport verification include Explosives, Flame, Flame Over Circle, Gas Cylinder, Corrosive, Skull and Crossbones, and Environmental Hazard. However, even for Exclamation Mark and Health Hazard pictograms, it is important not to assume ordinary cargo until the SDS transport information section has been reviewed.
Cases Where GHS Labels and Transport Dangerous Goods Determination Diverge
GHS labeling does not always align with the classification of dangerous goods for transport. In practice, there are cases where GHS labels are present but the cargo is not classified as dangerous for transport, and cases where GHS labels are not prominent but the cargo qualifies as dangerous goods for transport.
| Pattern of Divergence | Typical Examples | Practical Judgment | Documents/Parties to Confirm |
|---|---|---|---|
| GHS label present, but not classified as dangerous goods for transport | Displays such as exclamation marks or health hazard symbols appear, but no UN number is present in the SDS transport information section, so it is not classified as dangerous goods for transport. | Do not automatically classify as dangerous goods based solely on GHS labeling; instead, organize the assessment based on the SDS transport information and confirmation from the manufacturer. | SDS, non-dangerous goods certificate, manufacturer’s confirmation |
| GHS label present, and classified as dangerous goods for transport | Labels such as flame, gas cylinder, corrosive, or skull and crossbones are present, and the SDS transport information section includes a UN number or dangerous goods class. | Check the dangerous goods declaration, transport labels, and acceptance status with shipping lines and airlines. | SDS, dangerous goods declaration, shipping line/airline responses |
| GHS label not prominent, but classified as dangerous goods for transport | The product label may not clearly show it, but transport regulations require checks for items such as lithium batteries, aerosols, or alcohol-containing products. | Confirm transport dangerous goods classification based on product name, ingredients, usage, SDS, and product specifications. | Product specifications, SDS, manufacturer confirmation |
| Non-dangerous goods explanation conflicts with SDS | The shipper states the goods are non-dangerous, but the SDS transport information section includes a UN number or dangerous goods class. | Reconfirm with the shipper, and if necessary, verify classification with the shipping line, airline, and CFS treating as dangerous goods. | Shipper, manufacturer, SDS, non-dangerous goods certificate |
| Classified as non-dangerous for maritime transport, but requires confirmation for air transport | Although acceptance is possible for maritime transport, there are restrictions or issues under airline or IATA dangerous goods regulations. | When transport mode changes, do not apply maritime classification decisions directly; reconfirm with the airline side. | Airlines, air freight forwarders, SDS, air dangerous goods regulations |
| Warehouse or CFS requests additional documents due to GHS labeling | Even when transport classification is non-dangerous, SDS submission may be required for on-site safety or storage reasons. | Confirm transport dangerous goods classification separately from the warehouse or CFS acceptance conditions. | CFS, warehouse, SDS, non-dangerous goods certificate |
Freight forwarders should avoid making determinations based solely on the presence or absence of GHS labels. It is necessary to check a combination of GHS labels, SDS, actual package labels, transport information, dangerous goods declarations, and acceptance conditions.
Confirmation Workflow in Freight Forwarder Operations
For cargo with GHS markings or those that may contain chemicals, confirm in the following order:
| Step | What to Check | Guidance for Decision | Common Bottlenecks |
|---|---|---|---|
| 1. Inspect the actual cargo and exterior markings | Check GHS pictograms, dangerous goods labels, UN number, product name, and case marks. | Determine if chemical or dangerous goods confirmation is necessary. | Lack of exterior photos or inability to verify markings on the actual cargo. |
| 2. Obtain the SDS | Confirm the SDS is the latest version and that the product name and manufacturer match the cargo. | Avoid using outdated or incorrect product SDS for arrangements. | Shippers may submit older versions or SDS of similar products. |
| 3. Review hazard information on the SDS | Verify GHS classification, pictograms, signal words, and hazard statements. | Confirm consistency between the cargo label and the SDS. | The cargo label and SDS may sometimes not align. |
| 4. Check transportation information section of the SDS | Confirm UN number, proper shipping name, hazard class, packaging group, and marine pollutant status. | Identify whether it qualifies as dangerous goods for transport purposes. | Transportation details may be missing or unclear. |
| 5. Confirm per mode of transport | Check conditions for maritime transport, air transport, domestic delivery, and warehouse intake. | Verify cases where maritime carriage is permitted but air transport is not. | Decisions for sea transport are sometimes incorrectly applied to air transport. |
| 6. Verify acceptance conditions | Confirm acceptance with shipping lines, airlines, NVOCCs, CFS, and warehouses. | Ensure that even if documents classify cargo as dangerous goods, the cargo can actually be accepted. | Shipping lines may accept cargo, but CFS might refuse it. |
| 7. Prepare markings and documentation | Check dangerous goods declaration, transport labels, exterior markings, non-dangerous goods certificates, and manufacturer confirmations. | Prevent rejection at in-gate, acceptance refusals, or delays in loading and shipment. | Missing labels or documents may be discovered on the day of in-gate. |
Verification of SDS, Actual Labels, and Dangerous Goods Declarations
For cargo with GHS labels, it is essential to verify the consistency of the SDS, actual product labels, dangerous goods declarations, and invoice details.
| Verification Item | Details to Confirm | Action if Discrepancies Are Found | Contact Party |
|---|---|---|---|
| Product Name | Check if the names on the invoice, SDS, actual label, and dangerous goods declaration match. | Confirm with the shipper or manufacturer to identify the correct product. | Shipper, Manufacturer |
| GHS Pictograms | Verify that the pictograms on the actual label correspond to the hazard information in the SDS. | Check if the SDS is outdated or if it corresponds to a different product. | Shipper, Manufacturer |
| UN Number | Ensure the UN number in the SDS transport information and the dangerous goods declaration are consistent. | Revise the dangerous goods declaration and re-confirm acceptance. | Shipper, Shipping Line, Airline |
| Dangerous Goods Class | Confirm that the class indicated in the SDS, dangerous goods declaration, and transport label match. | Verify if there are differing requirements between maritime and air transport. | Shipper, Shipping Line, Airline, CFS |
| Packaging Group | If applicable, confirm that the packaging group and conditions are consistent. | Recheck packaging and labels as needed. | Shipper, Manufacturer, Dangerous Goods Officer |
| Marine Pollutant | Check for alignment between SDS details and declarations for marine transport. | Confirm the need for Marine Pollutant markings and declarations. | Shipper, Shipping Line, CFS |
| Non-Dangerous Goods Statement | Verify that there are no contradictions between the non-dangerous goods certificate and transport information in the SDS. | Hold treatment as general cargo and reconfirm with the shipper. | Shipper, Manufacturer, CFS |
Comparison Table of Freight Forwarders' Involvement Scope
| Category | What Can Be Supported | What Should Not Be Concluded | Practical Response |
|---|---|---|---|
| When Checking Actual Labels | Confirm GHS pictograms, product name, and presence of external markings. | Do not conclude cargo is dangerous goods solely based on GHS labeling. | Proceed to verify information in the SDS transport section. |
| When Receiving SDS | Confirm it is the latest version and matches the relevant product. | Do not decide transport eligibility only because an SDS is available. | Check transport information section, UN number, and hazard class. |
| When Receiving Non-Dangerous Goods Explanation | Verify consistency among non-dangerous goods certificate, SDS, and product specifications. | Do not treat cargo as general goods solely based on the shipper’s statement that it is not dangerous. | If inconsistencies exist, reconfirm with the shipper or manufacturer. |
| When Confirming with Shipping Lines | Confirm UN number, hazard class, quantity, packaging, and acceptance for ocean transport. | Do not assume that if the shipping line accepts the cargo, the CFS or warehouse will also accept it. | Also confirm conditions with CFS, warehouse, and consolidators. |
| When Confirming with Airlines | Confirm acceptance, packaging, and quantity restrictions under IATA Dangerous Goods Regulations. | Do not conclude that if sea transport is accepted, air transport will also be accepted. | Separate confirmation is required for air transport. |
| When Confirming with CFS and Warehouses | Confirm storage, cargo handling, in-gate acceptance, and required documentation. | Do not conclude CFS or warehouse confirmation is unnecessary just because cargo is non-dangerous for transport. | If GHS labeling is present, confirm acceptance conditions. |
| When Checking Dangerous Goods Declaration | Verify consistency between SDS transport section and declaration’s UN number, class, and packaging group. | Do not assume content confirmation is unnecessary if a declaration has been submitted. | Cross-check with SDS, actual labels, and external markings. |
| When Explaining to the Shipper | Organize and communicate confirmed points, unresolved issues, additional documentation, and acceptance status. | Do not proceed treating the cargo as general goods without confirming documents. | Keep supporting documentation and reconfirm as needed. |
Common Practical Issues
| Case | Issues | Documents / Contacts to Confirm | Recommended Actions |
|---|---|---|---|
| GHS pictograms are on the outer packaging but no dangerous goods declaration was made | There may be no confirmation of the cargo’s dangerous goods classification for transport. | SDS, actual labels, shipper, manufacturer | Check the transport information section of the SDS and submit a dangerous goods declaration if required. |
| The SDS indicates non-dangerous goods, but the physical label shows hazard markings | The SDS may be outdated, belong to a different product, or only reflects hazard information under GHS without transport classification. | SDS, photos of actual labels, manufacturer confirmation | Verify consistency between the actual label and the SDS. |
| Product name on invoice does not match the product name on the SDS | A different product’s SDS may have been used for documentation. | Invoice, SDS, product model number, manufacturer name | Obtain the correct SDS and reconfirm acceptance criteria. |
| Shipping arrangements are based on an outdated SDS version | Hazardous properties and transport information may have been updated. | Latest SDS, manufacturer confirmation letter | Obtain the most recent SDS and reconfirm with the shipping line, airline, and CFS. |
| Accepted for sea transport, but rejected for air transport | Dangerous goods regulations and acceptance conditions differ between maritime and air transport. | SDS, airline response, IATA dangerous goods documents | When switching to air transport, reassess acceptance, costs, and lead times. |
| GHS markings require acceptance confirmation on warehouse in-gate | Warehouses or CFS may require safety confirmation for storage and cargo handling. | SDS, non-dangerous goods certificate, warehouse response | Separate from transport classification, confirm the warehouse acceptance conditions. |
| Contradiction between non-dangerous goods certificate and SDS transport information | It may be unclear if the cargo can proceed as general cargo. | Non-dangerous goods certificate, SDS, manufacturer confirmation | Reconfirm with the shipper and, if needed, treat as dangerous goods. |
| Chemicals with inconspicuous GHS markings are handled as general cargo | Transport regulations may be overlooked for alcohol-containing items, aerosols, lithium battery-related cargo, etc. | Product name, ingredients, SDS, product specification | For chemicals, batteries, and spray products, always check the SDS regardless of GHS markings. |
4-Column Assessment Checklist
| Check Point | Party to Confirm With | Items to Verify | Action If Issues Are Found |
|---|---|---|---|
| When receiving cargo with GHS labeling | Shipper / Manufacturer | Verify SDS, product name, physical label, and GHS pictograms. | Do not base dangerous goods classification solely on GHS markings; confirm the transport information section of the SDS. |
| When obtaining the SDS | Shipper / Manufacturer | Confirm it is the latest version, matches the actual cargo, and the transport information section is clear. | If suspected to be an outdated version or for a different product, request a corrected SDS submission. |
| When the SDS transport information section includes a UN number | Shipper / Shipping Line / Airline | Confirm the UN number, official transport name, hazard class, and packaging group. | Verify the dangerous goods declaration, transport labels, and acceptance conditions. |
| When the SDS transport information section is empty or unclear | Shipper / Manufacturer | Check hazardous goods classification documentation, non-dangerous goods certificates, or manufacturer confirmation letters. | Do not proceed as general cargo without completing verification. |
| When a non-dangerous goods certificate is submitted | Shipper / Manufacturer | Verify consistency with the SDS, physical labels, and product specifications. | If contradictions appear, withhold general cargo handling and reconfirm. |
| When switching from maritime to air transport | Airline / Air Agent / Shipper | Check acceptance under air dangerous goods regulations, packaging, and quantity limits. | Do not assume maritime assessments apply; reconfirm for air transport requirements. |
| When bringing cargo into a CFS or warehouse | CFS / Warehouse / Consolidator | Confirm receiving conditions, storage requirements, and required documents for cargo with GHS markings. | Request additional documents, non-dangerous goods certificates, or reconfirm classification as dangerous goods. |
| When physical labels and documentation do not match | Shipper / Manufacturer / Delivery Company | Verify product name, GHS markings, UN number, hazard class, and exterior labels. | Withhold in-gate, shipment, or loading; request corrected documentation or resubmission. |
Example 1: Case Where GHS Labeling Exists but Cargo Is Classified as Non-Dangerous for Transport
This case involved a detergent product with an exclamation mark GHS pictogram on its outer packaging, and the shipper requested ocean transport.
When the freight forwarder reviewed the SDS, it showed skin irritation in the hazardous properties section, but no UN number was listed in the transport information section, and according to the IMDG Code, it was classified as non-dangerous goods.
In this situation, the booking should not be made as dangerous goods solely based on the presence of a GHS label. Instead, the freight forwarder should rely on the SDS transport information section, a non-dangerous goods certificate, and manufacturer confirmation as evidence, and confirm with the shipping line and CFS as necessary.
However, warehouses or CFS may require SDS submission for operational safety reasons. The fact that the cargo is not dangerous for transport does not automatically mean that safety checks for storage and handling can be skipped.
Example 2: Case Where Dangerous Goods Are Identified from GHS Labels and SDS Transport Information
This case involves paint packaging displaying the flame GHS pictogram, with the SDS indicating it as a flammable liquid.
Upon checking the SDS transport information section, the UN number, proper shipping name, hazard class, and packaging group were all noted. In this situation, it is necessary to proceed with arrangements as dangerous goods transportation rather than merely verifying the chemical label.
The freight forwarder should confirm the dangerous goods declaration, transport labels, container and packaging standards, and the acceptance eligibility of the shipping line or airline as well as the CFS.
Especially for LCL consolidation, even if the shipping line accepts the cargo, the CFS or consolidation operator may not. Therefore, once GHS labels are verified, it is important to proceed simultaneously with dangerous goods booking and CFS acceptance confirmation.
Example 3: Case of Contradiction Between Non-Dangerous Goods Certificate and SDS
In this case, the shipper explained that the cargo was non-dangerous goods and submitted a non-dangerous goods certificate; however, the SDS transport information section included a UN number and dangerous goods class.
Relying solely on the non-dangerous goods certificate to handle the cargo as regular goods is risky. The freight forwarder should point out the inconsistency between the non-dangerous goods certificate and the SDS to the shipper and request confirmation from the manufacturer or submission of corrected documentation.
If it is confirmed that the cargo requires dangerous goods handling, the freight forwarder should recheck acceptance as dangerous goods with the shipping line, airline, CFS, or warehouse.
In this situation, it is crucial not only to check the presence of GHS markings but also to ensure consistency between the SDS and the non-dangerous goods declaration. Ignoring contradictions between documents could result in in-gate refusals, shipment delays, and additional costs.
Example 4: Case Where Acceptance Is Possible by Sea but Not by Air
This case involves chemical samples for which the shipping line confirmed acceptance for sea transport, but the shipper later requested a switch to air transport to shorten the delivery time.
In this situation, acceptance under sea transport does not guarantee the same acceptance by air. Air transport is subject to additional requirements such as IATA Dangerous Goods Regulations, airline acceptance conditions, restrictions on passenger and cargo aircraft loading, quantity limits, and packaging standards.
The freight forwarder should reconfirm with the airline or air agent the SDS, UN number, hazard class, packaging group, quantity, and packaging form.
If acceptance by air is denied, the freight forwarder should present the shipper with options such as maintaining sea transport, using an alternate flight, splitting the samples, changing packaging, or postponing shipment.
Items to Confirm with the Shipper
- Whether the latest version of the SDS is available.
- Whether the GHS labels match the information on the SDS.
- Whether the transport information section of the SDS includes the UN number, hazard class, and packaging group.
- Whether transport conditions differ between maritime and air transport.
- Whether the actual labels, outer packaging markings, and dangerous goods labels are appropriate.
- If the cargo is classified as non-dangerous, whether supporting documentation is provided.
- Whether there are no contradictions between the non-dangerous goods certificate and the SDS.
- Whether the shipping line, airline, CFS, and warehouse can accept the shipment.
Common Misunderstandings
GHS labeling is an important indicator for identifying dangerous goods, but relying solely on the labels can lead to misunderstandings.
| Misunderstanding | Practical Consideration | What Should Be Checked |
|---|---|---|
| If GHS labels are present, the cargo is always a transport dangerous good | GHS labels indicate chemical hazards, but they do not always correspond directly to transport dangerous goods classifications. | Check the transport information section on the SDS, UN number, and hazard class. |
| If there are no GHS labels, the cargo is not dangerous | Even if labels are not prominent, the cargo may still qualify as a transport dangerous good. | Verify the product name, ingredients, purpose, SDS, and product specifications. |
| If there is a non-dangerous goods certificate, an SDS is unnecessary | It is important to check for contradictions between the non-dangerous goods certificate and the SDS. | Confirm the hazard and transport information on the SDS. |
| Cargo accepted for maritime transport can always be accepted for air transport | Acceptance conditions for dangerous goods differ between maritime and air transport. | Confirm according to each mode of transport. |
| Judgment can be based solely on the manufacturer’s product label | While the product label is important, transport dangerous goods classification should be verified against the SDS and transport regulations. | Cross-check the label, SDS, dangerous goods declaration, and acceptance conditions. |
| If the SDS includes GHS pictograms, a dangerous goods declaration is always required | Even with GHS pictograms, the cargo may not qualify as a transport dangerous good. | Check the SDS transport information section, UN number, and hazard class presence. |
| If there is no UN number, no further checking is needed | Absence of a UN number may indicate an outdated SDS, insufficient transport information, or inconsistencies with product labels. | Verify the latest SDS, confirm with the manufacturer, and review any non-dangerous goods certificates. |
| Warehouses and CFS will accept cargo unconditionally if it is not a transport dangerous good | Even if classified as non-dangerous for transport, additional checks may be required based on GHS labeling or storage safety considerations. | Confirm warehouse and CFS acceptance conditions, the SDS, and exterior labeling. |
Points Freight Forwarders Should Note
Freight forwarders should avoid treating GHS labeling simply as “customs-related labeling” or “manufacturer safety markings.”
GHS labeling serves as a key trigger for determining whether cargo falls under dangerous goods regulations. In particular, overlooking GHS markings on cargo such as paints, adhesives, cleaning agents, fragrances, inks, reagents, alcohol-containing items, aerosol products, and lithium battery-related shipments could cause issues with transportation arrangements.
- For cargo with GHS labeling, always check the Safety Data Sheet (SDS).
- Do not determine dangerous goods classification based on GHS labeling alone.
- Cross-check the SDS, actual container labels, dangerous goods declarations, and invoice details.
- Confirm separate conditions for maritime and air transport.
- If there are any uncertainties, consult with the shipper, manufacturer, shipping line, airline, CFS, or warehouse in advance.
- Even when proceeding on the basis that cargo is non-dangerous, retain the supporting documentation for that determination.
Summary
GHS labeling is a system for displaying the hazards and risks of chemicals on containers or packaging through pictograms, signal words, hazard statements, and precautionary statements.
For freight forwarder operations, GHS labeling serves as an important indicator when identifying dangerous goods. However, the presence of GHS labeling does not necessarily mean the item qualifies as dangerous goods under international transport regulations.
The key is to cross-check the GHS labels, SDS, actual cargo labels, dangerous goods declarations, UN numbers, hazard classes, and the acceptance conditions for maritime and air transport.
When encountering GHS labeling, it is essential neither to automatically classify the cargo as dangerous goods nor to overlook it as regular cargo. Instead, confirm the transport information section in the SDS and verify, in light of the actual mode of transport, packaging, and acceptance conditions, whether the shipment can be safely carried.
This article’s main point is to treat GHS labeling not just as chemical labeling but as a practical checkpoint linking SDS, UN numbers, hazard classes, dangerous goods declarations, and the acceptance conditions of shipping lines, airlines, CFS facilities, and warehouses.
